Specs_DLA_Standby_Generator_Pre-Alteration_Assessment_Report_-_Vol_3.pdf

Asbestos and Lead-Based Paint Building Inspections in Region 5

At

Battle Creek Federal Center Building 1B (Bldg. MI0538BC)

50 North Washington Avenue Battle Creek, Michigan

For

GSA Public Buildings Service Great Lakes Region

U.S. General Services Administration 230 South Dearborn Street, Room 3500

Chicago, Michigan 60604-1696

Report Date: August 26, 2014

7600 N. 16th Street, Suite 110 Phoenix, AZ 85020

(602) 266-8288

Contract Number: GS-05P-13-FA-A-0035 Task Order No.: GS-P-0514-FA-5007

ADN: PJ4EA0656

Appendix A to Specification Section 02 82 13.00 10 VOL 3

Asbestos and Lead-Based Paint Building Inspection Report TRC Project No: 220533

TABLE OF CONTENTS

EXECUTIVE SUMMARY ...................................................................................................... I

1.0 INTRODUCTION

2.0 ASBESTOS SAMPLING AND ANALYSIS

2.1 SAMPLING PROCEDURES

2.2 PHYSICAL ASSESSMENT

2.3 PLM ANALYSIS METHODOLOGY

2.4 FINDINGS AND RESULTS

2.5 ACM CONCLUSIONS AND RECOMMENDATIONS

2.5.1 Identified ACMs

2.5.2 Assumed ACMs

2.5.3 Recommendations

3.0 ASBESTOS MANAGEMENT

3.1 RESPONSE ACTION OPTIONS

3.2 RECOMMENDED RESPONSE ACTIONS

3.2.1 ACM in Poor Condition:

3.2.2 ACM in Fair Condition:

3.2.3 ACM in Good Condition:

3.3 PREVENTATIVE MEASURES

3.3.1 Maintenance

3.3.2 Condition Monitoring

3.3.3 Notification

3.3.4 Training

3.4 RECOMMENDATIONS FOR FUTURE BUILDING INSPECTIONS AND RECORDKEEPING

4.0 LIMITED LEAD-BASED PAINT SAMPLING AND ANALYSIS

4.1 GENERAL INFORMATION

4.2 SAMPLING PROCEDURES

4.3 LEAD ANALYTICAL METHODOLOGY

4.4 DEFINITION OF LEAD-BASED PAINT (LBP)

4.5 FINDINGS AND RESULTS

4.6 LBP CONCLUSIONS AND RECOMMENDATIONS

4.6.1 Non-Mandatory Best Practices

5.0 EXCLUSIONS

5.1 ASBESTOS BUILDING INSPECTION EXCLUSIONS

5.2 LIMITED LEAD-BASED PAINT BUILDING INSPECTION EXCLUSIONS

6.0 DISCLAIMER

7.0 STATEMENT OF COMPLETION & REPORT SIGNATORY

APPENDICES

GSA IRIS Asbestos-Containing Materials Spreadsheet .................................................. Appendix A Building Floor Plans and Sample Locations .................................................................... Appendix B Photographs ...................................................................................................................... Appendix C Cost Estimates to Remove ACM & Laboratory Analytical Reports ................................ Appendix D Project Personnel Certifications ....................................................................................... Appendix E

Asbestos and Limited Lead-Based Paint Building Inspection Report TRC Project No: 220533 i

EXECUTIVE SUMMARY

TRC Environmental Corporation (TRC) contracted with the U.S. General Services Administration (GSA) to perform asbestos and limited lead-based paint building inspections for the Battle Creek Federal Center Building 1B (Building MI0538BC) located at 50 North Washington Avenue in Battle Creek, Michigan (Site). The purpose of the building inspection was to complete baseline building inspections, in general accordance with the AHERA regulations, and cost estimates to establish GSA’s environmental liability for asbestos. As directed by GSA, the collection of bulk material samples was to target discrete locations (insofar as reasonably practical) without damaging the esthetics of the facility. The building inspection encompassed suspect asbestos-containing materials (ACMs) and lead-based paint (LBP) associated with the building. The inspection was performed July 17, 2014 by Mr. Paul Semper of TRC, a State of Michigan Licensed Asbestos Inspector and Lead Risk Assessor. Bulk PLM samples were submitted to TRC Industrial Hygiene Laboratory in Windsor Connecticut, a National Voluntary Laboratory Approval Program (NVLAP) accredited laboratory. Paint chip samples were submitted to EMC Laboratories in Phoenix, Arizona, an Environmental Lead Laboratory Accreditation Program (ELLAP) certified laboratory.

ASBESTOS FINDINGS

The following building materials were determined to contain asbestos or were assumed to contain asbestos:

HM Material Location Asbestos Content

Approx.

Quantity

Friable/ Non-

Friable Condition

10.* Vibration Dampener

B1002, B1008, B1013, B2013, B2015, B2017

Assumed >1%

Square

Feet (SF)

Non- Friable

(NF)

Good

22.

Gray Frame

Caulking 101, 201 5%

Chrysotile 32 SF NF Good

34.* Roofing

Materials Roof Assumed

>1% 12,500

SF NF Good

HM = Homogenous Material; meaning a building material of the same composition, application, appearance, age, texture, color, etc.

*HM not sampled to preserve material integrity (non-destructive sampling methodology)

LEAD-BASED PAINT FINDINGS

In accordance with GSA’s criteria, lead-based paint (LBP) was not identified.

Asbestos and Limited Lead-Based Building Inspection Report TRC Project No: 220533

- 1 -

1.0 INTRODUCTION

TRC Environmental Corporation (TRC) contracted with the U.S. General Services Administration (GSA) to perform an asbestos and limited lead-based paint building inspection for the Battle Creek Federal Center Building 1B (Building MI0538BC) located at 50 North Washington Avenue in Battle Creek, Michigan (Site). The purpose of the building inspection was to complete baseline building inspections, in general accordance with the AHERA regulations, and cost estimates to establish GSA’s environmental liability for asbestos. As directed by GSA, the collection of bulk material samples was to target discrete locations (insofar as reasonably practical) without damaging the esthetics of the facility. The building inspection encompassed suspect asbestos-containing materials (ACMs) and lead-based paint (LBP) associated with the building. The inspection was performed July 17, 2014 by Mr. Paul Semper of TRC, a State of Michigan Licensed Asbestos Inspector and Lead Risk Assessor. Copies of training certificates and state licenses (where applicable) are presented in Appendix E, Project Personnel Certifications.

2.0 ASBESTOS SAMPLING AND ANALYSIS

2.1 Sampling Procedures

The asbestos building inspection, bulk material sampling, material condition assessments, and analytical procedures were performed in accordance with the United States Environmental Protection Agency’s (USEPA) Asbestos Hazard Emergency Response Act (AHERA) 40 CFR Part

763. In general the building inspection procedures included first identifying materials suspected to contain asbestos and then collecting samples of the suspect materials for laboratory analysis to determine if the materials are ACMs. The USEPA-AHERA defines ACM as any material containing greater than one percent (>1.0%) asbestos.

Suspect material homogeneity determination is based on the following criteria:

Similar physical characteristics (e.g., same age, color, and texture, etc.);

Application (e.g., sprayed-on, troweled-on, assembly into a system, etc.); and Material function (e.g., thermal insulation, floor tile, wallboard system, stucco plaster, fireproofing, adhesives, asphalt roofing, etc.).

In accordance with USEPA-AHERA sampling methodology, multiple samples are collected for each suspect homogenous material application in order to reduce chances of reporting false negatives. The number of samples collected for each material type was based on the information listed in the following table, and found in the AHERA regulation.

Bulk Sampling Strategy*

Material Homogeneous Areas Units Minimum Number of Samples*

Thermal System Insulation Less than 6 SF or LF of patched

Less than 6 SF or LF of non-patched

More than 6 SF

SF/LF

3 samples per homogenous area

- 2 -

Material Homogeneous Areas Units Minimum Number of Samples*

Friable Surfacing less than 1,000 1,000 to 5,000 more than 5,000

SF

SF

SF

Non-friable Surfacing - - - SF 3 Friable and Non-friable Miscellaneous Materials

- - - LF / SF / EA 3

*Fewer samples may be collected of materials found in limited quantity or accessibility as determined by the Inspector SF = square feet; LF = linear feet; EA = each

Sampling of building materials was conducted using hand tools to cut or bore small samples of materials. Once a piece of material is dislodged, the sample was placed into a laboratory provided sampling container and labeled with a unique identification number. The material condition was also inspected and assessed for damage.

2.2 Physical Assessment

A physical assessment of each suspect homogenous material was performed by the TRC inspector to determine the condition of the materials. The following describes how the material was assessed by the TRC inspector. Assessment includes visual inspection and physically touching the material as well as making considerations for future disturbance to a material.

This information is combined to determine appropriate response actions and developing management plans/procedures for identified ACMs. In accordance with GSA’s Inventory Reporting and Information System (IRIS) and based on the physical assessment findings, the ACMs were placed into one of the following three categories:

Good = Undamaged Fair = Damaged (less than 10% locally or 25% distributed) Poor = Significantly damaged (at or over 10% locally or 25% distributed)

Because the physical assessment is used to determine which response actions will be chosen to manage the asbestos, proper identification and assessment of ACM are vital to the effective implementation of the management program.

2.3 PLM Analysis Methodology

Laboratory analytical services were provided by TRC Industrial Hygiene Laboratory in Windsor Connecticut, a National Voluntary Laboratory Approval Program (NVLAP) accredited laboratory

(NVLAP# 101424-0).

PLM samples were analyzed utilizing the USEPA’s Test Methods: Methods for the determination of Asbestos in Bulk Building Materials [USEPA/600/R-93/116 (1993)], and the McCrone Research Institute’s The Asbestos Particle Atlas as method references. Using this method, analysis was performed by using visual estimation of the sample composition and slide preparation(s) for microscopic examination and asbestos identification. The samples were analyzed for asbestos (i.e. chrysotile, amosite, crocidolite, anthophyllite, and actinolite/tremolite), fibrous non-asbestos constituents (e.g. mineral wool, cellulose, etc.), and non-fibrous constituents. Using a stereoscope, the Microscopist visually estimated relative amounts of each constituent by determining the volume of each constituent in proportion to the total volume of the sample.

- 3 -

One positive result exceeding 1.0% asbestos content for a material is all that is required to deem a material as ACM by definition. As is standard practice in the industry, if a certain sampled material is determined to have asbestos exceeding 1% in concentration, the laboratory is instructed to stop analysis (“Stop-Positive”) for materials with multiple samples collected. Thus, the remaining subsequent samples of this same material would not be analyzed and a positive determination for the material is concluded (i.e. the material is classified as ACM).

2.4 Findings and Results

Based on GSA’s protocol, the following table presents the location and quantities of suspect building materials identified during this building inspection as well as applicable analytical results:

Approx.

Quantit y

Friable/ Non-

Friable Condition

1.

Gray/Pink Carpet

Squares and Mastic

Basement 1 – Offices

None Detected

(ND)

5,650 Square

Feet (SF)

Non-Friable

(NF)

Good

2.

Gray Cove Base and Mastic Basement 1 – Throughout ND 280 SF NF Good

3.

2' x 2' Pin and

Fissures Ceiling Tile

Basement 1 – Throughout

ND 8,410 SF Friable (F) Good

4.

Smooth Drywall

System Basement 1 and 2

– Throughout

ND

43,240

SF

F Good

5.

Raised Floor Post

Mastic

Basement 1 – B1008, B1009, B1010, B1011

ND 1290 SF NF Good

6.

Plaster with Skim

Coat Basement 1 –

Around Columns ND 520 SF NF Good

7.

Fiberglass Ceiling

Tile Finish Basement 1 –

B1013 ND 2400 SF NF Good

8.

Gray Duct

Sealant Basement 1 – Above Ceiling ND 1280 SF NF Good

9.

Door Frame

Caulking

Basement 1 – Doors and View

Windows ND 140 SF NF Good

10.* Vibration Dampener

B1002, B1008, B1013, B2013, B2015, B2017

Assumed >1.0%

120 SF NF Good

11. Not Used

12. Not Used

13.*

FRP

(Wainscoting) Mastic

B1018 Not

Sampled† 18 SF NF Good

14. Not Used

15. Leak Sealant Tape

Ceiling Deck ND 10 SF NF Good

16. Not Used

17.

Blue/Green/Gray

Floor Coating Floors 1 and 2 –

UPS Building ND 2700 SF NF Good

18. Not Used

- 4 -

Content

Approx.

Quantit y

Friable/ Non-

Friable Condition

19.

Red Firestop

Caulking Floors 1 and 2 –

UPS Building ND 16 SF NF Good

20. Not Used

21. HVAC Sealant Floor 2 – Around

Air Handlers ND 24 SF NF Good

22.

Gray Frame

Caulking 101, 201

5% Chrysotile

24 SF NF Good

23.

Hard Packed

Elbows

Basement 2 – Mechanical

Rooms ND 200 SF F Good

24.

Black Cove Base and Brown Adhesive

Stair Well St1-B2 ND 20 SF ND Good

25.

HVAC Canvas

Wrap

Basement 2 – Mechanical

Rooms ND 1750 SF NF Good

26. Not Used

27. Smooth Drywall System

Basement 2 – Perimeter Wall of

Mechanical Rooms

ND 600 SF F Good

28.

Blue with Specks Carpet Squares and Glue

Basement 2 – B2011, B2013 ND 2,250 SF NF Good

29. Not Used

30. Not Used

31.

Black Cove Base and Tan Adhesive B2011 ND 15 SF NF Good

32.

Raised Floor Post

Mastic, Black

Basement 2 – Communication

Center ND 125 SF NF Good

33.* Gray Speckled Wall Covering B2008

Not Sampled†

960 SF Non-Friable Good

34.* Roofing

Materials Roof

Assumed >1%

12,500

SF

Non- Friable

Good

HM = Homogenous Material; meaning a building material of the same composition, application, appearance, age, texture, color, etc.

*HM not sampled to preserve material integrity (non-destructive sampling methodology) †Per GSA this material is outside of the scope of work to establish GSA’s environmental liability for asbestos consideration but should be sampled prior to any renovation or demolition activities that will impact this material.

A copy of the laboratory analytical report concerning the materials sampled and analyzed during this asbestos building inspection may be referenced in Appendix D. Sample location diagrams are included in Appendix B.

2.5 ACM Conclusions and Recommendations

2.5.1 Identified ACMs

Results of this asbestos building inspection identified the following ACMs at the subject building structure:

- 5 -

Gray Frame Caulking

Unless otherwise noted above in the table, the materials identified were found to be in Good condition.

2.5.2 Assumed ACMs

The following un-sampled suspect building materials identified during this building inspection were assumed to be asbestos containing (as illustrated in the table and results above):

Vibration Dampener Roofing Materials

2.5.3 Recommendations

Identified and assumed ACM should be managed via an Asbestos Management Plan designed by an AHERA accredited Asbestos Management Planner.

Prior to performing renovation or demolition in the building, GSA should perform a Pre- Alteration Assessment to determine if asbestos containing materials will be impacted by the proposed project. The Pre-Alteration Assessment should include destructive investigation to identify potential hidden/concealed materials that were inaccessible while conducting this building inspection.

If disturbed or removed, ACM and/or assumed ACM would require special handling and disposal in accordance with applicable asbestos regulations. For additional recommendations please see section 3.0 Asbestos Management.

3.0 ASBESTOS MANAGEMENT

3.1 Response Action Options

AHERA identifies five possible response actions for managing asbestos in buildings:

• Operations and Maintenance (O&M) Program -- This is a program of work practices designed to maintain friable ACBM in good condition and ensure cleanup of asbestos fibers previously released. An effective O&M program can prevent further release by minimizing and controlling friable ACBM disturbance or damage.

• Repair -- This involves returning damaged ACBM to an undamaged condition or to an intact state by replacing limited sections or patching damaged areas.

• Encapsulation -- This involves the treatment of ACBM with a material that surrounds or embeds asbestos fibers in an adhesive matrix to prevent the release of fibers. The encapsulant either creates a membrane over the surface (bridging encapsulant) or penetrates the material and binds its components together (penetrating encapsulant).

Both types of encapsulant are applied to the material surface using airless spray equipment at low pressure to reduce release of fibers during the application.

• Enclosure -- This involves creating an airtight, impermeable, permanent barrier around ACBM to prevent the release of asbestos fibers into the air. The barrier is

- 6 -typically attached physically or sprayed on. For example, materials such as PVC or corrugated metal may be fastened around insulated piping, or a barrier may be constructed around asbestos fireproofing on structural members by spraying material that cures into a hard shell.

• Removal -- This involves the taking out or the stripping of substantially all ACBM from a damaged area, a functional space, or a homogeneous area in a school building.

3.2 Recommended Response Actions

Under the AHERA model, the response action to be taken must be "sufficient to protect human health and the environment." Once it is determined which response actions meet these criteria, the person responsible for facility asbestos management may choose the action that is the "least burdensome." Based on this criteria and the material physical assessments, TRC recommends the following Response Actions for ACMs identified at this Site.

3.2.1 ACM in Poor Condition:

Significantly damaged ACM should be removed by a licensed asbestos abatement contractor.

The removal should be performed in accordance with AHERA guidelines and all applicable regulations.

3.2.2 ACM in Fair Condition:

Damaged ACM should be repaired and/or removed by a licensed asbestos abatement contractor.

The repair and/or removal should be performed in accordance with AHERA guidelines and all applicable regulations.

3.2.3 ACM in Good Condition:

Intact and undamaged ACM should be managed in place via an Asbestos Management Plan (AMP) designed by an AHERA Accredited Management Planner.

3.3 Preventative Measures

3.3.1 Maintenance

Identified ACM, assumed ACM and presumed ACM should be maintained in a Good and undamaged condition to reduce asbestos exposure. These materials should be managed via an Asbestos Management Plan designed by an AHERA accredited Asbestos Management Planner.

Any work proposed to be done in areas where ACMs, assumed ACMs, or presumed ACMs are present should be approved by GSA prior to commencement. Any contractor(s) scheduled to perform work in areas of known, assumed or presumed ACMs should be made aware of the potential hazards present.

Abatement: Should abatement action become necessary for ACM/Assumed/Presumed ACM, GSA should contact an approved environmental consultant to evaluate the ACM and determine the appropriate response action. The consultant should prepare an abatement action specification and monitor the abatement activity to help ensure proper procedures and work methods are utilized by the abatement contractor.

- 7 -

3.3.2 Condition Monitoring

All building personnel should take an active role in monitoring the condition of ACMs throughout the subject building. The condition of the identified ACMs/Assumed ACMs should be monitored regularly.

If an ACM is observed to be in non-intact condition (fair or poor condition), GSA should be notified and the correct Response Action implemented in accordance with Section 3.2 of this report.

3.3.3 Notification

GSA should share the contents of this report with employees and individuals who may come into contact with the identified areas.

All potentially impacted parties, including but not limited to building staff, tenants, occupants, contractors and vendors, should be notified of the presence of ACMs and instructed not to disturb them and to report any disturbances.

3.3.4 Training

The Asbestos Program Manager as well as maintenance and custodial staff should receive Asbestos Awareness Training in accordance with AHERA guidelines.

3.4 Recommendations for Future Building Inspections and Recordkeeping

Prior to performing renovation or demolition in the building, GSA should perform a Pre- Alteration Assessment to determine if ACM will be impacted by the proposed project. The Pre- Alteration Assessment should include destructive investigation to identify potential hidden/concealed materials that were inaccessible while conducting this building inspection.

Additional building inspections should be performed prior to disturbance of assumed ACM, presumed ACM or any additional suspect ACM to verify the asbestos content of un-sampled materials.

The facility should keep and maintain on site all records associated with asbestos related activities conducted at the site, including but not limited to building inspections, sampling data, response actions, operations and maintenance activities, training records, etc.

4.0 LIMITED LEAD-BASED PAINT SAMPLING AND ANALYSIS

4.1 General Information

TRC conducted a limited lead-based paint inspection of the subject building structure to inventory and collect samples of the predominant paints found in the building. Mr. Paul Semper, a licensed State of Michigan Department of Community Health Lead Risk Assessor, performed the inspection on July 17, 2014. A copy of Mr. Semper’s license is included in Appendix E.

- 8 -

The inspection included identification and preparation of an inventory of accessible predominant surface paint colors observed throughout the building and limited sampling of paints where feasible, without damaging aesthetics of the paint.

4.2 Sampling Procedures

The limited lead-based paint building inspection utilized limited bulk paint sampling with laboratory analysis for lead. Inspectors collecting paint chip samples attempt to collect a minimum of 2-4 square inch area, where all layers of paint are collected from a given substrate.

Sampling tools usually consist of scrapers, razor blades, sharp chisels, and, if needed, a heat gun useful to help loosen paint from its substrate. The most common paint sampling method is to manually scrape paint directly off the substrate. The goal is to remove all layers of paint equally, but to exclude the substrate. Including substrate in the sample dilutes the lead content if results are reported in ppm, µg/g, or weight percent. As each paint sample is collected, the scrapings are placed into laboratory supplied containers and labeled with unique sample identification numbers. For each sample, the inspector records the paint color, sampling location, substrate, and type of building component onto sample information logs and chain-of-custody documents.

Following the collection of each sample, the sampling tools are wiped/washed to avoid cross-contamination among samples.

4.3 Lead Analytical Methodology

As identified in TRC’s scope of work for this building inspection, paint chip sampling was specified. Paint chip samples were submitted to EMC Laboratories in Phoenix, Arizona, an Environmental Lead Laboratory Accreditation Program (ELLAP) certified laboratory (AIHA- LAP, LLC Laboratory Number 101586) and analyzed using Flame AAS (SW 846 Method 7420) methods. The laboratory analytical report is included in Appendix D.

4.4 Definition of Lead-Based Paint (LBP)

HUD defines LBP as any surface coating that contains lead at or above 5,000 parts per million (ppm) (0.5%). In addition, per GSA’s criteria paint and coatings that contain lead at or above 5,000 ppm or 0.5% are considered LBP.

4.5 Findings and Results

The following table presents the location and quantities of suspect paints sampled during this building inspection as well as applicable analytical results:

Sample/ Paint ID Location Color Condition

Square Footage

Reporting Limit

Lead Content

LP-1

Mega Center – Throughout All

Surfaces White Good NA 0.014 BRL*

LP-2

UPS Building Floors

1 & 2 – Floor Blue/Gray Fair NA 0.010 BRL*

LP-3

UPS Building Floor 2 – Walls, Ceiling

White Good NA 0.010 0.024

LP-4

UPS Building –

Step-ups Yellow Good NA 0.010 0.032

- 9 -

Paint ID

Location Color Condition Square Footage

Reporting Limit

Lead Content

LP-5

UPS Building – Exterior Metal Staircase and

Railing

Light Blue Poor NA 0.010 0.053

LP-6

UPS Building – Exterior Doors

Brown Good 3 Doors 0.021 0.068

LP-7

UPS Building Floor 1 – Metal Stairs and

Railing Black Fair NA 0.010 0.052

LP-8

UPS Building Floor

1 – Walls and Ceiling

Blue/Gray Good NA 0.010 0.014

LP-9

Electrical Room –

Walls Green Good NA 0.010 0.171

LP-10 Corridor Walls Gray Good NA 0.010 BRL*

LP-11

Basement 2 –

Mechanical Room Walls

Light Green Good NA 0.010 0.043

LP-12

Basement 2 –

Mechanical Room Floor

Gray Fair NA 0.010 0.018

LP-13

Basement 2 –

Communication Center Walls

Blue Fair NA 0.010 0.053

*BRL = Below Reportable Limit (meaning no lead was detected in the quantity of sample submitted)

The painted surfaces and components identified at this building were observed to be in Good or Fair condition at the time of the inspection. Laboratory analytical report of bulk paint sample analyses, the sampling locations, and corresponding paint conditions are included in Appendix D. Sample location diagrams are included in Appendix B.

4.6 LBP Conclusions and Recommendations

No LBPs were identified at the site.

Paints and coatings identified in this report as having concentrations of lead less than 5,000 ppm are not considered definition LBP, but may contain smaller concentrations of lead. Such paints can be categorized as lead-containing paints (LCP), meaning the paint contains lead, but in relatively low level concentrations. Contractor’s and construction workers should be aware that the Lead-In-Construction Standard contains provisions to regulate work activities (including LCP) where airborne lead exceeds the OSHA action level of 30 micrograms of airborne lead dust per cubic meter of air, regardless of the concentration of the lead in paints and coatings being disturbed at the job site. Therefore, compliance with the Lead-In- Construction Standard is required with regards to worker protection and exposure evaluation when paints containing any amount of lead are disturbed. Contractors are advised to read and understand this Standard to ensure OSHA compliance.

Prior to bid of work activities that will disturb LBP and/or paints with low levels of lead, TRC recommends preparation of a Lead-Paint Stabilization specification to accompany renovation/ demolition project documents. Such specification should be designed to assist contractors in

- 10 -the proper procedures to stabilize LBPs (and other paints with levels of detected lead) prior to their disturbance and incorporate the appropriate methods for exposure evaluation, work practices, and engineering controls to minimize exposure risk to workers. Prior to performing renovation or demolition in the building, GSA should perform a Pre-Alteration Assessment to determine if LBP will be impacted by the proposed project.

4.6.1 Non-Mandatory Best Practices

USEPA's Lead Renovation, Repair and Painting Rule (RRP Rule) requires that firms performing renovation, repair, and painting projects that disturb lead-based paint in homes, child care facilities and pre-schools built before 1978 have their firm certified by USEPA (or a USEPA authorized state), use certified renovators who are trained by USEPA-approved training providers and follow lead-safe work practices.

Any contractor or maintenance staff who disturbs more than six square feet of lead-based paint, replaces windows or does any demolition while working in a pre-1978 home, school or day-care center, must be Lead-Safe Certified and trained in lead-safe work practices.

5.0 EXCLUSIONS

This building inspection is not intended to be comprehensive in nature and some materials were not to be treated as ACMs or LBPs and TRC has been instructed by the GSA Contracting Officer Representative, Mr. Philip A. Ramos, to exclude them from this report.

5.1 Asbestos Building Inspection Exclusions

Note that the asbestos building inspection was not comprehensive and does not constitute a pre-demolition/renovation survey. Per GSA, TRC did not perform destructive sampling for asbestos of any roofing system materials, wood, metal, terrazzo, stone, glass, cement, mortar, or bricks.

Additionally, GSA requested that ceramic tile and grout not be treated or included in the building inspection as suspect ACM. In addition as outlined in the RFP, with the exception of roofing materials, TRC was not to treat or include these building materials in the building inspection as suspect ACM. Further, per GSA, TRC did not perform destructive sampling for asbestos of floor baseboards or their adhesives or drywall systems.

5.2 Limited Lead-Based Paint Building Inspection Exclusions

Note that the limited lead-based paint building inspection was not comprehensive and does not constitute a HUD compliant lead paint inspection. Identified paints that were not sampled were not assumed and have been omitted from this report.

6.0 DISCLAIMER

The content presented in this report is based on data collected during the site inspection, review of pertinent regulations, requirements, guidelines and commonly followed industry standards, and information provided by the GSA, agents, and representatives.

The work has been conducted in an objective and unbiased manner and in accordance with generally accepted professional practice for this type of work. TRC believes the data and analysis to be accurate and relevant, but cannot accept responsibility for the accuracy or completeness of available documentation or possible withholding of information of other

- 11 -parties. Findings presented in this report are only representative of conditions observed at the time of the building inspection and can change with time due to aging, weathering, remodeling, or other changes or site activities beyond TRC’s control.

This report is designed to aid the property owner, architect, construction manager, general contractor, and subcontractors in locating ACM, LBP and/or paints containing detectable levels of lead. This report is not intended for, and may not be utilized as a bidding document or as an abatement project specification document. The listed materials and respective locations given are specific only to those areas. TRC makes no representation regarding the extent of ACM and LBP, lead-containing paints or conditions pertaining thereto of areas located outside the contract scope of work.

OSHA regulations must still be followed for materials found to contain less than 1.0% asbestos;

however, restrictions are lifted for licensed asbestos abatement contractors to perform the abatement/disturbance work and the material may be disposed of as non-hazardous waste. Any sample can be subjected to the more stringent point count method of analysis to more precisely determine the actual asbestos content.

Per GSA, the building inspection could not employ the use of destructive sampling. Hidden building materials (e.g. old floor mastic patches hidden under carpeting), other than those discussed in this report, could be uncovered when removing building finishes during demolition, renovation, or maintenance activities. Any materials uncovered during such activities that are not addressed in this building inspection report, or presumed ACM containing material must be sampled by an accredited asbestos inspector prior to any disturbance, or they must otherwise be assumed to be ACM.

7.0 STATEMENT OF COMPLETION & REPORT SIGNATORY

TRC hereby certifies completion of the asbestos building inspection for the subject site, as defined by our contract scope of work, and has prepared this report of deliverable as evidence thereof. TRC appreciates the opportunity to be of service to the GSA. Should there be any questions regarding the information presented in this report, please feel free to contact us.

Sincerely, TRC Environmental Corporation

Prepared by: Reviewed by:

Kacey Swindle Josh Lewis, CIE Industrial Hygienist BSI Practice Leader

APPENDIX A

GSA IRIS ASBESTOS-CONTAINING MATERIALS

SPREADSHEET

(Submitted Under Separate Cover)

APPENDIX B

BUILDING FLOOR PLANS

AND

SAMPLE LOCATIONS

SENSITIVE BUT UNCLASSIFIED (SBU)

PROPERTY OF THE UNITED STATES GOVERNMENT

FOR OFFICIAL USE ONLY

Do not remove this notice

Properly destroy or return documents when no longer needed

FILE NO.

SCALE:

DATE PRINTED:

PROJ. NO.

PROJECT:

SHEET TITLE:

REVISIONDATE

2.

1.

NO.

3.

BY APP'D.

File Location: File Name:

Plot Information:

Layout Name: B2MI0538-Bldg1b-SampLocL:\Graphics\ProjectsByName\800 - Reporting and testing\Michigan\Battle Creek MI00358 (MI0535) - Bld 1B KS NONE COLLINS, RASHELLE ---- ANSI A (8.50 X 11.00 INCHES) August 27, 2014 0.3869 ----

B2

08/24/2014

PS

PS MI0538-Bldg1b-SampLoc.dwg

220533

BATTLE CREEK, MI

BUILDING 0538 ASBESTOS/LEAD PT. ASSESSMENT

GSA

SPC

LEGEND:

APPROXIMATE SAMPLE LOCATION

SAMPLING LOCATION MAP

NOT TO SCALE

PLM-69

PLM-62

PLM-61

PLM-65

PLM-63

PLM-56

PLM-57

PLM-55

PLM-64

PLM-48

PLM-66

PLM-53

PLM-46

PLM-52

PLM-60

PLM-58

PLM-59

PLM-67

PLM-68

PLM-54

PLM-47

PLM-49

PLM-50

PLM-51

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BUILDING 0538 ASBESTOS/LEAD PT. ASSESSMENT

GSA

SPC

LEGEND:

APPROXIMATE SAMPLE LOCATION

SAMPLING LOCATION MAP

NOT TO SCALE

PLM-5

PLM-4

PLM-1

PLM-25

PLM-30

PLM-29

PLM-28

PLM-3

PLM-7

PLM-17

PLM-20

PLM-10

PLM-19

PLM-16

PLM-18

PLM-21

PLM-26

PLM-24

PLM-8

PLM-11

PLM-2

PLM-23

PLM-12

PLM-22

PLM-6

PLM-27

PLM-9

PLM-13

PLM-14

PLM-15

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BUILDING 0538 ASBESTOS/LEAD PT. ASSESSMENT

GSA

SPC

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SAMPLING LOCATION MAP

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PLM-43

PLM-44

PLM-38

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BUILDING 0538 ASBESTOS/LEAD PT. ASSESSMENT

GSA

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SAMPLING LOCATION MAP

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PLM-40

PLM-45

PLM-39

PLM-42

PLM-33

PLM-41

PLM-37

PLM-31

PLM-32

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SPC

ACM LOCATION MAP

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LEGEND:

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RUBBER VIBRATION DAMPENER (HM-10)

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BUILDING 0538 ASBESTOS/LEAD PT. ASSESSMENT

GSA

SPC

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BUILDING 0538 ASBESTOS/LEAD PT. ASSESSMENT

GSA

SPC

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220533

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BUILDING 0538 ASBESTOS/LEAD PT. ASSESSMENT

GSA

SPC

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B2-Pb

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BUILDING 0538 ASBESTOS/LEAD PT. ASSESSMENT

GSA

SPC

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B1-Pb

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220533

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BUILDING 0538 ASBESTOS/LEAD PT. ASSESSMENT

GSA

SPC

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LP-1

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01-Pb

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BATTLE CREEK, MI

BUILDING 0538 ASBESTOS/LEAD PT. ASSESSMENT

GSA

SPC

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LP-7

LP-6

LP-8

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02-Pb

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220533

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BUILDING 0538 ASBESTOS/LEAD PT. ASSESSMENT

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LP-3

LP-2

LP-4

LP-5

APPENDIX C

PHOTOGRAPHS

Battle Creek Building 1B (MI0538)

HM #1: Gray/Pink Carpet Squares and Mastic HM #2: Gray Cove Base and Mastic

Secure Room TRC not given permission to take photos

Secure Room TRC not given permission to take photos

HM #3: 2’ x 2’ Ceiling Tile with Pinholes and Fissures

HM #4: Smooth Drywall System

Secure Room

HM #5: Raised Floor Post Mastic

HM #6: Plaster with Skin Coat

Secure Room

HM #7: Fiberglass Ceiling Tile Finish HM #8: Gray Duct Sealant

HM #9: Door Frame Caulking HM #10: Rubber Vibration Dampener

HM #11: Not Used HM #12: Not Used

HM #13: FRP Mastic HM #14: Not Used

HM #15: Leak Sealant Tape HM #16: Not Used

HM #17: Floor Coating HM #18: Not Used

HM #19: Red Fire Stop Caulking HM #20: Not Used

HM #21: HVAC Sealant HM #22: Gray Frame Caulking

HM #23: Hard Pack Elbows HM #24: Black Cove Base and Brown Adhesive

HM #25: HVAC Canvas Wrap HM #26: Not Used

HM #27: Smooth Drywall System HM #28: Blue Carpet with Specks and Glue

HM #29: Not Used HM #30: Not Used

Secure Room

HM #31: Black Cove Base and Tan Adhesive HM #32: Black Raised Floor Post Mastic

HM #33: Gray Speckled Wall Covering HM #32: Roof

APPENDIX D

COST ESTIMATES TO REMOVE ACM

LABORATORY ANALYTICAL REPORTS

ASBESTOS ABATEMENT COST ESTIMATES

The table below provides cost estimates for removal of ACM prior to demolition and is based on TRC’s experience with similar projects/materials, knowledge of the industry and working with abatement contractors throughout the United States, and historical unit costs for abatement of similar materials under similar conditions. The pricing was developed using unit rates we’ve seen from abatement contractors. These costs are rough estimates only and assume the ACM will all be removed during one mobilization on consecutive working days.

HM

ID#

Material Location Approx.

Quantity

Approximate Cost to

Remove

10. Vibration Dampener B1002, B1008, B1013, B2013, B2015, B2017

120 Square Feet (SF)

$7,000

22. Gray Frame Caulking 101, 201 32 SF $1,500

34. Roofing Materials Roof 12,500 SF $51,000

Approximate Total Removal Cost:

$59,500.00

The above costs do not include asbestos consultant costs for related services, such as project design, abatement specifications, abatement oversight, and clearance assessment. Costs for removal can vary depending on various factors, such as inflation, union labor requirements, distance to the job site, prevailing wages, experience of the work force, and market conditions.

LABORATORY ANALYTICAL REPORTS

EMC LABS, INC.

9830 South 51 st Street, Suite B-109 / PHOENIX, ARIZONA 85044 / 480-940-5294 or 800-362-3373 / FAX 480-893-1726 emclab@emclabs.com

ANALYST: QA COORDINATOR:

Jason Thompson Kurt Kettler

Rev. 11/30/08

LEAD (Pb) IN PAINT CHIP SAMPLES

EMC SOP METHOD #L01/1 EPA SW-846 METHOD 7420

EMC LAB #: L53156 DATE RECEIVED: 07/31/14

CLIENT: TRC Solutions REPORT DATE: 08/07/14

DATE OF ANALYSIS: 08/07/14

CLIENT ADDRESS: 7600 N. 16 Street, Suite 110 Phoenix, AZ 85020

P.O. NO.:

PROJECT NAME: BC – Bldg 1B – MI0538 PROJECT NO.: 220533 Ph3 T4

EMC #

L53156-

SAMPLE

DATE /14

CLIENT

SAMPLE #

DESCRIPTION

REPORTING

LIMIT

(%Pb by weight)

%Pb BY

WEIGHT

1 07/17 LP – 1 White 0.014 BRL

2 07/17 LP – 2 Blue / Gray 0.010 BRL

3 07/17 LP – 3 White 0.010 0.024

4 07/17 LP – 4 Yellow 0.010 0.032

5 07/17 LP – 5 Light Blue 0.010 0.053

6 07/17 LP – 6 Brown 0.021 0.068

7 07/17 LP – 7 Black 0.010 0.052

8 07/17 LP – 8 Blue / Gray 0.010 0.014

9 07/17 LP – 9 Green 0.010 0.171 ^ = Dilution Factor Changed * = Excessive Substrate May Bias Sample Results BRL = Below Reportable Limits # = Very Small Amount Of Sample Submitted, May Affect Result

This report applies to the standards or procedures identified and to the samples tested only. The test results are not necessarily indicative or representative of the qualities of the lot from which the sample was taken or of apparently identical or similar products, nor do they represent an ongoing quality assurance program unless so noted. Unless otherwise noted, all quality control analyses for the samples noted above were within acceptable limits.

Where it is noted that a sample with excessive substrate was submitted for laboratory analysis, such analysis may be biased. The lead content of such sample may, in actuality, be greater than reported. EMC makes no warranty, express or implied, as to the accuracy of the analysis of samples noted to have been submitted with excessive substrate. Resampling is recommended in such situations to verify original laboratory results.

These reports are for the exclusive use of the addressed client and are rendered upon the condition that they will not be reproduced wholly or in part for advertising or other purposes over our signature or in connection with our name without special written permission. Samples not destroyed in testing are retained a maximum of sixty (60) days.

EMC LABS, INC.

9830 South 51 st Street, Suite B-109 / PHOENIX, ARIZONA 85044 / 480-940-5294 or 800-362-3373 / FAX 480-893-1726 emclab@emclabs.com

ANALYST: QA COORDINATOR:

Jason Thompson Kurt Kettler

Rev. 11/30/08

LEAD (Pb) IN PAINT CHIP SAMPLES

EMC SOP METHOD #L01/1 EPA SW-846 METHOD 7420

EMC LAB #: L53156 DATE RECEIVED: 07/31/14

CLIENT: TRC Solutions REPORT DATE: 08/07/14

DATE OF ANALYSIS: 08/07/14

CLIENT ADDRESS: 7600 N. 16 Street, Suite 110 Phoenix, AZ 85020

P.O. NO.:

PROJECT NAME: BC – Bldg 1B – MI0538 PROJECT NO.: 220533 Ph3 T4

EMC #

L53156-

SAMPLE

DATE /14

CLIENT

SAMPLE #

DESCRIPTION

REPORTING

LIMIT

(%Pb by weight)

%Pb BY

WEIGHT

10 07/17 LP – 10 Gray 0.010 BRL

11 07/17 LP – 11 Light Green 0.010 0.043

12 07/17 LP – 12 Gray 0.010 0.018

13 07/17 LP – 13 Blue 0.010 0.053 ^ = Dilution Factor Changed * = Excessive Substrate May Bias Sample Results BRL = Below Reportable Limits # = Very Small Amount Of Sample Submitted, May Affect Result

This report applies to the standards or procedures identified and to the samples tested only. The test results are not necessarily indicative or representative of the qualities of the lot from which the sample was taken or of apparently identical or similar products, nor do they represent an ongoing quality assurance program unless so noted. Unless otherwise noted, all quality control analyses for the samples noted above were within acceptable limits.

Where it is noted that a sample with excessive substrate was submitted for laboratory analysis, such analysis may be biased. The lead content of such sample may, in actuality, be greater than reported. EMC makes no warranty, express or implied, as to the accuracy of the analysis of samples noted to have been submitted with excessive substrate. Resampling is recommended in such situations to verify original laboratory results.

These reports are for the exclusive use of the addressed client and are rendered upon the condition that they will not be reproduced wholly or in part for advertising or other purposes over our signature or in connection with our name without special written permission. Samples not destroyed in testing are retained a maximum of sixty (60) days.

APPENDIX E

PROJECT PERSONNEL CERTIFICATIONS

Asbestos and Lead-Based Paint Building Inspections in Region 5

At

Battle Creek Federal Center Building 2 (Bldg. MI0503BC)

74 North Washington Avenue Battle Creek, Michigan

For

GSA Public Buildings Service Great Lakes Region

U.S. General Services Administration 230 South Dearborn Street, Room 3500

Chicago, Michigan 60604-1696

Report Date: September 1, 2014

7600 N. 16th Street, Suite 110 Phoenix, AZ 85020

(602) 266-8288

Contract Number: GS-05P-13-FA-A-0035 Task Order No.: GS-P-0514-FA-5007

ADN: PJ4EA0656

TABLE OF CONTENTS

EXECUTIVE SUMMARY ...................................................................................................... I

1.0 INTRODUCTION

2.0 ASBESTOS SAMPLING AND ANALYSIS

2.1 SAMPLING PROCEDURES

2.2 PHYSICAL ASSESSMENT

2.3 PLM ANALYSIS METHODOLOGY

2.4 FINDINGS AND RESULTS

2.5 ACM CONCLUSIONS AND RECOMMENDATIONS

2.5.1 Identified ACMs

2.5.2 Assumed ACMs

2.5.3 Recommendations

3.0 ASBESTOS MANAGEMENT

3.1 RESPONSE ACTION OPTIONS

3.2 RECOMMENDED RESPONSE ACTIONS

3.2.1 ACM in Poor Condition:

3.2.2 ACM in Fair Condition:

3.2.3 ACM in Good Condition:

3.3 PREVENTATIVE MEASURES

3.3.1 Maintenance

3.3.2 Condition Monitoring

3.3.3 Notification

3.3.4 Training

3.4 RECOMMENDATIONS FOR FUTURE BUILDING INSPECTIONS AND RECORDKEEPING

4.0 LIMITED LEAD-BASED PAINT SAMPLING AND ANALYSIS

4.1 GENERAL INFORMATION

4.2 DEFINITION OF LEAD-BASED PAINT (LBP)

4.3 FINDINGS AND RESULTS

4.4 LBP CONCLUSIONS AND RECOMMENDATIONS

4.4.1 Non-Mandatory Best Practices

5.0 EXCLUSIONS

5.1 ASBESTOS BUILDING INSPECTION EXCLUSIONS

5.2 LIMITED LEAD-BASED PAINT BUILDING INSPECTION EXCLUSIONS

6.0 DISCLAIMER

7.0 STATEMENT OF COMPLETION & REPORT SIGNATORY

APPENDICES

GSA IRIS Asbestos-Containing Materials Spreadsheet .................................................. Appendix A Building Floor Plans and Sample Locations .................................................................... Appendix B Photographs ...................................................................................................................... Appendix C Cost Estimates to Remove ACM & Laboratory Analytical Reports ................................ Appendix D Project Personnel Certifications ....................................................................................... Appendix E Previous Asbestos & Lead-Based Paint Building Inspection Report .............................. Appendix F i

EXECUTIVE SUMMARY

TRC Environmental Corporation (TRC) contracted with the U.S. General Services Administration (GSA) to perform asbestos and limited lead-based paint building inspections for the Battle Creek Federal Center Building 2 (Building MI0503BC) located at 74 North Washington Avenue in Battle Creek, Michigan (Site). The purpose of the building inspection was to complete baseline building inspections, in general accordance with the AHERA regulations, and cost estimates to establish GSA’s environmental liability for asbestos.